271059/271347/E-02472/E-04036 Representative Edcel C. Lagman, substituted by Albay First District Representative Krisel B. Lagman, et al. Vs. The Congress of the Philippines, et al./Aquilino “Koko” Pimentel III and Pantaleo “Bebot” Alvarez Vs. Lucas P. Bersamin, in his capacity as executive secretary, and Amenah F. Pangandaman, in her capacity as secretary of the Department of Budget and Management/Filipinos for Peace, Justice and Progress Movement, Inc. (FPJPM), represented by its president and chairperson, Joseph F. Cadsawan, and Gloria T. Puzon, chapter Officer Vs. The House of Representatives, et al./Edgar R. Erice and Leila De Lima Vs. The Senate of the Philippines, et al. — Official PDF

Decision 49 G.R. Nos. 271059, 271347, E~02472 and • E-04036 SECTION 25 ..... (2) No provision or enactment shall be embraced in the general appropriations bill unless it relates specifically to some particular appropriation therein. Any such provision or enactment shall be limited ih its operation to the appropriation to which it relates. Farinas v. Executive Secretary37 explained the rationale for the proscription of riders: The proscription is aimed against the evils of the so-called omnibus bills and log-rolling legislation as well as surreptitious and/or unconsidered encroaches. The provision merely calls for all parts of an act relating to its subject finding expression in its title. To determine whether there has been compliance with the constitutional requirement that the subject of an act shall be expressed in its title, the Court laid down the rule that - • • • ' • • • Constitutional provisions relating to the subject matter and titles of statutes should not be so narrowly construed as to cripple or impede the power of legislation. The requirement tl1at the subject of an act shall be expressed in its title should receive a reasonable and not a technical construction. It is sufiicient if the title be comprehensive enough reasonably to include the general object which a statute seeks to effect, without expressing each and every end and means necessary or convenient for tl1e accomplishing of that object. Mere details need not be set forth. The title need not be an abstract or index of the Act.238 (Citations omitted) Atitiw v. Zamora239 discussed when a prov1s10n m a general appropriations bill complies with the test of gennaneness: Therefore, in order that a provision or clause in a general appropriations bill may comply with the test of germaneness, it must be · particular, unambiguous, and appropriate. A provision or clause is particular if it relates specifically to a distinct item of appropriation in the bill and does not refer generally to the entire appropriations bill. It is unambiguous when its application or operation is apparent on the face of the bill and it does not necessitate reference to details or sources outside the appropriations bill. It is an appropriate provision or clause when its subject rna!ter does not necessan·1 y lmve to b e treate d m• a separate l eg1s• l at10n.• 240 (Emphasis supplied) Here, the assailed provision on Unprogrammed Appropriations does not constitute as a rider in the 2026 GAA. It is a distinct item of appropriation-·- 237 463 Phil. 179 (2003) [Per J. Callejo, Sr., En Banc]. 23:s Id. at 198. 239 508 Phil. 321 (2005) [Per J. Tinga, En Banc]. 240 Id at 336.